How This Briefing Works
This report opens with key findings, then maps the gaps between what Firmable discloses and what BLACKOUT observed at runtime. From there: what it means for your organization, what to do about it, and the detection data and evidence underneath.
Key Findings
Pre-Consent Activity
Firmable was observed loading and executing before user consent was obtained on 11% of sites where it was detected.
Claims vs. Observed Behavior
pending
“Unknown”
Requires claims extraction via CDT
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use Firmable
- →Immediately audit Firmable deployment for consent bypass and cross-domain tracking
- →Demand contractual prohibition on visitor data sharing across customer base
- →Require third-party audit of identification methodology and match rate accuracy
- →Implement consent-first deployment where behavioral capture only activates after explicit opt-in
If You're Evaluating Firmable
- →Request data deletion for all previously identified visitors under GDPR Article 17
- →Evaluate alternative visitor identification with first-party strategies (progressive profiling, gated content)
- →Consider whether identification benefits justify maximum regulatory exposure and competitive intelligence leakage
- →Assess total cost of ownership including legal defense, compliance monitoring, and potential regulatory fines
Negotiation Leverage
- →Firmable VRS 80 = Broker (100) + Counselor (100) maximum threat. Visitor data sharing = direct competitor subsidy. This is existential risk.
- →Cross-domain sync (BTI-C08) + consent bypass (BTI-C09) = systematic GDPR violation. Regulatory investigation would result in maximum fines.
- →Session recording (BTI-C07) + behavioral biometrics (BTI-C06) = special category data processing without legal basis. Demand documentation or terminate.
- →Data cooperative model means your traffic intelligence feeds competitors. Negotiate exclusive data processing or exit immediately.
- →Ask: What visitor data is shared across customers? How are individuals notified? What is the data breach history? Expect evasive answers.
- →Recommendation: Contract termination. The competitive intelligence leakage alone justifies exit; regulatory exposure makes this legally indefensible.
Runtime Detections
BLACKOUT observed this vendor's JavaScript executing in a live browser and classified each hostile behavior using our BTI-C (Behavioral Threat Intelligence — Capability) taxonomy. These are not theoretical risks — each code below was triggered by something we watched this vendor's code actually do.
Evasion infrastructure, auditor bypass
Impact: Tag behavior varies based on privacy tool detection, presenting compliant facade to auditors while conducting full tracking on standard browsers.
Keystroke/mouse tracking
Impact: Mouse tracking, scroll patterns, and keystroke dynamics create unique visitor signatures enabling cross-session and cross-device identification that survives cookie deletion.
Full session replay
Impact: Full session capture including form inputs and page interactions creates PII exposure risk and enables behavioral profiling users cannot detect.
Identity stitching
Impact: Cookie syncing across multiple domains enables visitor tracking across unrelated websites, creating systematic privacy violation and competitive intelligence leakage.
Ignoring CMP signals
Impact: Tracking continues after consent rejection, demonstrating systematic disregard for user privacy rights and creating ongoing GDPR violation liability.
Device identification
Impact: Browser and device fingerprinting creates persistent identifiers that defeat user privacy controls and enable long-term tracking across contexts.
PII deanonymization
Container/loader (neutral)
IOC Manifest
Indicators of compromise across 4 categories. Use for detection rules, CSP policies, or Pi-hole blocklists.
Ecosystem & Supply Chain
Evidence Artifacts
Artifacts collected during analysis, available with evidence-tier access.
Complete network capture with all requests and responses
267 detection signatures across scripts, domains, cookies, and network endpoints