How This Briefing Works
This report opens with key findings, then maps the gaps between what Netcore 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
Analysis pending. Findings will appear here once intelligence collection is complete.
Claims vs. Observed Behavior
pending
“Awaiting scanner verification”
No scanner data available for Netcore CE SDK runtime behavior
data_collection
“Data points around users are stored on the client side with none flowing to Netcore servers”
This claim applies only to client-side nudges — the core SDK, CDP, and campaign systems necessarily transmit behavioral data to Netcore infrastructure for processing
consent
“DPDPA 2023 compliant”
Indian DPDPA compliance may not satisfy GDPR requirements for EU visitors — particularly around anonymous tracking and progressive de-anonymization consent requirements
data_collection
“Users voluntarily submit personal data”
The Addressable Anonymous feature collects partial PII from interactions before full voluntary registration, blurring the line between voluntary submission and passive collection
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
Recommended Actions for Netcore
- →Audit Netcore CE JavaScript SDK initialization to ensure it does NOT begin tracking before your consent management platform collects valid consent — the SDK's default behavior of immediately tracking anonymous visitors likely violates GDPR Article 5(3) requirements for EU-facing websites.\n2. Review the Addressable Anonymous feature configuration and determine whether partial PII collection (email/phone capture before full registration) aligns with your privacy policy's description of data collection practices.\n3. Assess data residency and sovereignty implications — confirm where Netcore stores and processes your customer behavioral data, particularly if you have EU customers, and whether Standard Contractual Clauses or adequacy decisions cover India-to-EU data transfers.\n4. Evaluate web push notification service worker scope to ensure it is limited to notification delivery and does not enable additional background data collection or tracking beyond what users explicitly consented to.\n5. Negotiate data portability rights covering all channels — ensure you can export email lists, behavioral segments, automation workflows, WhatsApp templates, and CDP profiles in standard formats to reduce switching costs and avoid vendor lock-in.
Negotiation Leverage
- →Key leverage points for Netcore Cloud procurement: (1) The Indian martech market is competitive — Clevertap, MoEngage, and WebEngage offer comparable omnichannel engagement capabilities, providing strong alternatives leverage. (2) The Addressable Anonymous feature creates GDPR compliance exposure — negotiate enhanced indemnification and demand that anonymous tracking is disabled by default for EU-facing deployments. (3) Push for contractual clarity on data residency, requiring that EU customer data remains within EU/EEA infrastructure if applicable. (4) Request a complete subprocessor list with data flow documentation, particularly given the Unbxd acquisition expanded Netcore's data processing scope into product discovery. (5) Negotiate data portability guarantees covering all channels (email, SMS, WhatsApp, push, CDP profiles, behavioral segments) in machine-readable formats. (6) Demand audit rights to verify data segregation between clients on the shared platform. (7) The DPDPA 2023 attestation is a positive signal but may not satisfy EU DPA expectations — use this gap as leverage for GDPR-specific contractual commitments and processing restrictions.
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
88 detection signatures across scripts, domains, cookies, and network endpoints