How This Briefing Works
This report opens with key findings, then maps the gaps between what Loom 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
Subprocessor Disclosure
Runtime analysis detected 34+ distinct third-party vendors on loom.com, including Demandbase, Mutiny, Cheq, TrenDemon, Clarity, and major ad platforms
Pre-Consent Activity
Loom was observed loading and executing before user consent was obtained on 78% of sites where it was detected.
Pre-Consent Tracking
77.5% pre-consent tracking rate across 71 detections; 19 vendors fire before any consent interaction
Identity Resolution
Demandbase and Mutiny are B2B identity resolution platforms that explicitly re-identify visitors by company and individual
Undisclosed Party
Not in privacy policy
Claims vs. Observed Behavior
Subprocessor Disclosure
“Atlassian discloses 22 subprocessors for Loom/Atlassian products”
Runtime analysis detected 34+ distinct third-party vendors on loom.com, including Demandbase, Mutiny, Cheq, TrenDemon, Clarity, and major ad platforms
Scan data shows vendor_slug count of 34+ unique vendors with pre_consent=true for 19 of them
Pre-Consent Tracking
“Honors GPC and opt-out requests per Atlassian privacy policy”
77.5% pre-consent tracking rate across 71 detections; 19 vendors fire before any consent interaction
intel_detections query shows pre_consent_pct = 77.5%
Identity Resolution
“May aggregate or de-identify information per privacy policy”
Demandbase and Mutiny are B2B identity resolution platforms that explicitly re-identify visitors by company and individual
Both vendors detected with pre_consent=true on loom.com
Advertising Stack Transparency
“Data sale disclosed to Third Party Advertising Providers”
Extensive ad platform presence (Meta, Google, LinkedIn, Twitter, TikTok, Reddit, Bing) but specific platforms not itemized
All major ad platforms detected firing pre-consent
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use Loom
- →Audit your CMP configuration — ensure all 34+ vendors detected on Loom properties are declared in your consent management
- →Implement Loom embeds through a consent-gated loader to prevent pre-consent tracking on your site from Loom's vendor stack
- →Review GDPR Article 28 documentation — add undisclosed Loom subprocessors (Demandbase, Mutiny, Cheq, TrenDemon, Clarity) to your records
- →Consider Loom Enterprise with custom data retention and privacy settings to control the tracking footprint
- →Monitor for Loom SDK updates that may introduce new tracking vendors onto your property without notice
If You're Evaluating Loom
- →Request Atlassian's current SOC2 Type II report and compare controls against the 34+ vendors observed at runtime on loom.com
- →Perform runtime scan of any loom.com page to verify the current vendor footprint before procurement decision
- →Evaluate alternative video messaging tools with simpler tracking profiles (Tella, Sendspark) if embed privacy is critical
- →Negotiate DPA terms that explicitly address the subprocessor disclosure gap between Atlassian's list and runtime reality
- →Implement technical controls to sandbox Loom embeds from your main analytics and prevent cross-contamination of tracking data
Negotiation Leverage
- →Embed isolation: Loom videos carry identity resolution (Demandbase, Mutiny) and advertising pixels onto host sites. Require contractual guarantee that Loom embeds load zero third-party vendors on your property, or implement consent-gated embed loader.
- →Subprocessor reconciliation: 34+ vendors detected versus 22 Atlassian-disclosed subprocessors. Require Atlassian to provide complete subprocessor list specific to Loom product, covering all runtime JavaScript dependencies.
- →Pre-consent SLA: 77.5% pre-consent rate across 62 sites. Require contractual guarantee that Loom embeds and direct usage load zero tracking before consent, with liquidated damages per violation.
- →Data flow transparency: Demandbase and Mutiny deanonymize visitors to Loom-embedded pages. Require written documentation of all data flows triggered by Loom embeds on third-party sites versus direct loom.com usage.
- →Enterprise privacy configuration: Negotiate Loom Enterprise plan with custom data retention, disabled advertising pixels, and sandboxed embed mode that prevents third-party vendor loading on your property.
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
Keystroke/mouse tracking
Full session replay
Identity stitching
Ignoring CMP signals
Device identification
PII deanonymization
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
287 detection signatures across scripts, domains, cookies, and network endpoints