How This Briefing Works
This dossier opens with key findings, then maps the gap between what Rokt discloses and what BLACKOUT observed at runtime. From there: what it means for your organization, what to do about it, and the detection evidence underneath. BLACKOUT observes runtime browser behavior and cites the regulations that address each pattern — legal determinations are your counsel's call.
At a Glance
across 2 sites
vendor fires before consent
Briefing
Rokt delivers personalized checkout offers using behavioral analysis and session capture. Detected BTI codes indicate session recording (C07), behavioral biometrics (C06), consent bypass (C09), fingerprinting (C10), and defeat device behavior (C01) that monetizes your transaction data while creating privacy compliance gaps.
What This Means For You
Your checkout conversion rate improvements come at the cost of training Rokt's cross-merchant model. Competitors using Rokt benefit from your transaction patterns. If you achieve 5% conversion lift, competitors get same intelligence without paying your CPA.
Risk Channel Breakdown
Session recordings capture PII and payment interactions. If even partial data is excluded for compliance, conversion models become unreliable.
Real-time checkout behavior feeds Rokt recommendation engine across ALL customers. Your conversion optimization trains competitor offers. CAC subsidization score of 90 reflects direct demand signal leakage.
Expands attack surface
Session recording of checkout flow likely captures payment details and PII without explicit consent. Creates PCI-DSS scope expansion and GDPR Article 32 violations (security of processing).
Threat Indicators
Runtime-observed (BTI-C)
Evasion infrastructure, auditor bypass
Keystroke/mouse tracking
Full session replay
Ignoring CMP signals
Device identification
Per-code narrative explanations of what each detected behavior means for your organization
Per-code evidence with full attribution chain, severity rankings, and consequence narratives See pricing →
Claims vs. Reality
BLACKOUT analyzed Rokt's public claims against observed runtime behavior and identified 1 contradiction.
Full claim-vs-reality gap analysis with claim text, observed behavior, severity, regulatory citations (GDPR, CCPA, ePrivacy), and evidence pointers per gap See pricing →
What To Do
4 for current users · 3 for evaluators
contractual leverage points
Role-specific actions (security / legal / marketing / procurement), full negotiation brief with contractual language, and BTI-code-specific consequences See pricing →
Supply Chain & Pairings
Full supply-chain mapping (loads / loaded-by lists with vendor identities) and the undisclosed-subprocessor list with observation evidence See pricing →