How This Briefing Works
This report opens with key findings, then maps the gaps between what Minerva 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
Minerva was observed loading and executing before user consent was obtained on 60% 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 Minerva
- →Conduct legal review of C06 behavioral biometrics collection against state biometric privacy laws (IL BIPA, TX, WA)
- →Audit cross-domain tracking (C08) against privacy policy disclosures and CPRA third-party sharing obligations
- →Query vendor: provide complete data flow diagram showing all identity graph partnerships and data cooperative arrangements
- →Model consent bypass impact: quantify percentage of behavioral data collected before CMP initialization
If You're Evaluating Minerva
- →Demand contractual prohibition on sharing resolved identities with third-party identity graphs and data cooperatives
- →Require monthly transparency reports listing all downstream consumers of customer behavioral and identity data
- →Negotiate data deletion guarantees: all behavioral profiles must be purged within 30 days of customer opt-out request
- →Replace with privacy-preserving analytics (server-side implementations) that eliminate client-side identity resolution entirely
Negotiation Leverage
- →Minerva identity resolution capabilities trigger GDPR DPIA requirements and CPRA sensitive PI protections. Behavioral biometrics (C06) likely violate state biometric privacy laws. Legal exposure: Our privacy counsel requires written confirmation of compliance with IL BIPA, GDPR Article 35, and CPRA 1798.121 opt-out mechanisms.
- →Cross-domain tracking (C08) and consent bypass (C09) create FTC deception liability. Privacy policies disclose analytics not comprehensive identity resolution and behavioral surveillance. Regulatory risk: Provide complete list of domains where visitor behavioral data is synchronized and legal basis for processing without explicit consent.
- →CAC inflation is measurable and permanent. Your identity graph partnerships sell our first-party customer intelligence to competitors. Quantify impact: What is the contractual mechanism to prohibit sharing resolved customer identities with any third-party vendors or data cooperatives?
- →If vendor refuses to eliminate identity graph data sharing, demand complete platform replacement. The compliance risk from undisclosed behavioral biometrics and consent bypass mechanisms exceeds any customer experience optimization value delivered by the platform.
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.
Keystroke/mouse tracking
Impact: Captures typing patterns, mouse movements, scroll behaviors, and interaction rhythms to create unique behavioral fingerprints that persist across sessions and enable identity resolution
Full session replay
Impact: Records complete interaction sessions including form inputs, navigation paths, and page engagement to build comprehensive behavioral profiles linked to resolved identities
Identity stitching
Impact: Synchronizes identity profiles across multiple organizational domains and third-party properties to create unified tracking infrastructure that follows users across web properties
Ignoring CMP signals
Impact: Loads identity resolution infrastructure before consent management platforms initialize, capturing behavioral signals regardless of user privacy choices
PII deanonymization
Impact: Deanonymizes website visitors by linking behavioral signals to email addresses, CRM records, and third-party identity graphs without explicit user knowledge or consent
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
361 detection signatures across scripts, domains, cookies, and network endpoints