How This Briefing Works
This report opens with key findings, then maps the gaps between what OpenSend 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
Consent Compliance
No GDPR mention in privacy policy, no CCPA mention, no consent banner, 25+ trackers firing without consent, explicit DNT refusal
Consent Laundering
Consent obtained on third-party publishing sites, not on the site where identification happens. Cross-domain PII transport via window.name bypasses same-origin policy.
CNAME Cloaking
t.opensend.com CNAME-cloaked to 191412.edge.hyros.com. All 43 first-party cookies sent to undisclosed Hyros infrastructure. Hyros not disclosed anywhere.
Pre-Consent Activity
OpenSend was observed loading and executing before user consent was obtained on 100% of sites where it was detected.
Cookie-Less Claim
Sets 39+ cookies on first visit. Uses localStorage as cookie alternative with JS-managed expiry. Falls back to fingerprinting for cookieless browsers.
Claims vs. Observed Behavior
Consent Compliance
“100% Legally Compliant”
No GDPR mention in privacy policy, no CCPA mention, no consent banner, 25+ trackers firing without consent, explicit DNT refusal
CDT MCP recon 2026-02-20: zero CMP detected, 43 cookies set pre-consent, 25+ third-party domains loaded, privacy policy text: We currently do not participate in any Do Not Track frameworks
Consent Laundering
“Opt-in consumer profiles”
Consent obtained on third-party publishing sites, not on the site where identification happens. Cross-domain PII transport via window.name bypasses same-origin policy.
window-name-unpacker.js source code: reads window.name for OSX:: prefix, base64-decodes JSON with firstname/lastname/email, injects into URL params via history.replaceState, clears window.name
CNAME Cloaking
“Protected by end-to-end encryption”
t.opensend.com CNAME-cloaked to 191412.edge.hyros.com. All 43 first-party cookies sent to undisclosed Hyros infrastructure. Hyros not disclosed anywhere.
DNS lookup: t.opensend.com → CNAME → 191412.edge.hyros.com → 52.205.62.94. Network request: GET /v1/lst/universal-script with all first-party cookies attached
Undisclosed Subprocessors
“Privacy policy lists Facebook, Google, Microsoft, Twitter as partners”
Also uses HubSpot (portal 24030046), ActiveCampaign (account 801465941), Fueled.io (API key exposed), Metricool, eulerapp.com/Bubble.io, Hyros (CNAME-cloaked), ipinfo.io — none disclosed
Network traffic analysis: 8+ third-party domains receiving data not listed in privacy policy or any subprocessor list
Session Recording
“No disclosure of session recording in privacy policy or on-page notice”
Microsoft Clarity (tag eqnd2gytr9) actively records full session replays of mouse movements, clicks, scrolls, and form interactions without any user disclosure or consent
CDT MCP: clarity.ms scripts loaded, _clck/_clsk cookies set, Bing/Clarity cookie sync active via c.bing.com
Encrypted Payloads
“Protected by end-to-end encryption”
All aggle.net request and response bodies use custom encryption preventing security audit. Security teams cannot determine what data is collected or what match results are returned.
Network traffic: POST to oirt-dev.aggle.net/csc, /evt, /ack, /ost all contain encrypted payloads (custom encoding, not standard base64)
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use OpenSend
- →Audit your DNS for CNAME records pointing to *.edge.hyros.com — OpenSend likely provisioned a t.yourdomain.com subdomain routing your visitors' cookies to undisclosed Hyros infrastructure
- →Review your CSP and network logs for traffic to aggle.net, cdn-t.aggle.net, oirt-dev.aggle.net — these are OpenSend's identity resolution endpoints
- →Demand OpenSend provide a complete subprocessor list including Hyros and verify your DPA covers all 8+ undisclosed third parties
- →Monitor localStorage for _oir_* keys that persist encrypted tracking data beyond cookie clearing with JavaScript-managed expiry
- →Require OpenSend to disable Microsoft Clarity session recording on your properties or add explicit disclosure and consent
If You're Evaluating OpenSend
- →Run a test deployment and capture a full HAR file — count third-party requests, cookies set pre-consent, and CNAME-cloaked destinations before signing
- →Request OpenSend's SOC 2 report, DPA, and complete subprocessor list — verify Hyros, Fueled.io, ActiveCampaign, and aggle.net are disclosed
- →Ask OpenSend to explain the window-name-unpacker.js cross-domain PII transport mechanism and its legal basis under GDPR Article 6
- →Verify CNAME cloaking: run nslookup on any subdomain they ask you to create — if it resolves to *.edge.hyros.com, that is undisclosed third-party tracking
- →Ask for explicit written confirmation that your visitor data is siloed, not shared with other clients, and not used to enrich their shared identity graph
Negotiation Leverage
- →CNAME cloaking to Hyros: t.opensend.com resolves to 191412.edge.hyros.com. All 43 first-party cookies are sent to Hyros infrastructure via this cloaked subdomain. Hyros is not disclosed in any privacy policy, DPA, or subprocessor list. Demand complete disclosure of all CNAME destinations provisioned on client domains and written confirmation that no tracking subdomain points to undisclosed third parties.
- →Cross-domain PII transport: window-name-unpacker.js passes firstname, lastname, and email between domains via window.name, injects PII into URL query parameters via history.replaceState, stores in sessionStorage, then clears window.name to destroy evidence. This bypasses same-origin policy and constitutes covert personal data processing under GDPR Article 5(1)(a). Demand written explanation of legal basis and right to disable this mechanism.
- →Zero consent mechanism: 25+ third-party domains and 43 cookies fire on page load with no CMP, no cookie banner, and no opt-out. OpenSend explicitly refuses DNT. Demand contractual guarantee that a consent gate will be deployed, or an indemnification clause covering all regulatory fines resulting from consent violations on sites running the OpenSend pixel.
- →Encrypted payloads preventing audit: All aggle.net request and response bodies use custom encryption preventing security audit. Your security team cannot determine what data is collected or what match results are returned. Demand technical documentation of all data fields collected and returned by the OIR SDK, right to audit decrypted payloads, and contractual guarantee that payload contents match documentation.
- →Undisclosed subprocessors: Active third parties not listed in privacy policy include Hyros, Fueled.io (API key 4peVNCRSnkRvsyKdJO1thfmqUxWnm7), ActiveCampaign (account 801465941), Metricool, eulerapp.com/Bubble.io, and Microsoft Clarity (tag eqnd2gytr9 with session recording). Demand complete subprocessor list with DPA coverage for each and right to approve or reject future subprocessor additions per GDPR Article 28(2).
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.
PII deanonymization
IOC Manifest
Indicators of compromise across 7 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
343 detection signatures across scripts, domains, cookies, and network endpoints