How This Briefing Works
This dossier opens with key findings, then maps the gap between what CookieHub discloses and what BLACKOUT observed at runtime. From there: what it means for your organization, what to do about it, and the detection evidence underneath. BLACKOUT observes runtime browser behavior and cites the regulations that address each pattern — legal determinations are your counsel's call.
At a Glance
across 8 sites
vendor fires before consent
Briefing
Cookie consent platform with behavioral fingerprinting (C06), session replay (C07), and consent bypass (C09) capabilities. Observed loading trackers pre-consent in half of monitored implementations.
What This Means For You
Regulators view CMP consent bypass as aggravating factor. When your compliance vendor is the compliance violation, enforcement actions carry higher penalties. GDPR Article 5(1)(f) violations compounded by bad faith demonstrated through tool selection.
Risk Channel Breakdown
Distorts attribution data
Deploys behavioral biometrics before consent, feeding tracking infrastructure it claims to protect against.
Expands attack surface
CMP vendor exhibiting consent bypass undermines entire compliance posture. Creates liability loop where the compliance tool is the compliance violation.
Threat Indicators
Runtime-observed (BTI-C)
Keystroke/mouse tracking
Full session replay
Ignoring CMP signals
Long-lived identifiers
Per-code narrative explanations of what each detected behavior means for your organization
Per-code evidence with full attribution chain, severity rankings, and consequence narratives See pricing →
Claims vs. Reality
BLACKOUT analyzed CookieHub's public claims against observed runtime behavior and identified 1 contradiction.
Full claim-vs-reality gap analysis with claim text, observed behavior, severity, regulatory citations (GDPR, CCPA, ePrivacy), and evidence pointers per gap See pricing →
What To Do
3 for current users · 3 for evaluators
contractual leverage points
Role-specific actions (security / legal / marketing / procurement), full negotiation brief with contractual language, and BTI-code-specific consequences See pricing →
Supply Chain & Pairings
Full supply-chain mapping (loads / loaded-by lists with vendor identities) and the undisclosed-subprocessor list with observation evidence See pricing →