How This Briefing Works
This dossier opens with key findings, then maps the gap between what Smartlook 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 3 sites
vendor fires before consent
Briefing
Smartlook provides session recording and replay capabilities marketed as user experience analytics. Captures complete user sessions including mouse movements, clicks, scrolls, and form interactions for playback analysis. Positions as product optimization tool while operating as comprehensive behavioral surveillance layer that records everything users do on-site.
What This Means For You
Product teams gain session replay insights but organization captures and stores comprehensive behavioral recordings that may include sensitive user data despite masking efforts. Third-party session storage creates data breach exposure and consent complexity. Recordings become liability in security incident or legal discovery scenarios.
Risk Channel Breakdown
Distorts attribution data
Captures complete user behavioral data including sensitive interactions and PII - session recordings become valuable asset for product analytics aggregators and UX intelligence platforms
Expands attack surface
Session recording without granular consent creates GDPR exposure, particularly around capturing sensitive input fields and inferring special category data from behavior
Threat Indicators
Runtime-observed (BTI-C)
Keystroke/mouse tracking
Full session replay
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 Smartlook'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
3 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 →