How This Briefing Works
This report opens with key findings, then maps the gaps between what WhoIsVisiting 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.
Disclosure Gaps
Claims vs. Observed Behavior
3 gaps
compliance
HIGH
They Claim
“Fully compliant with GDPR requirements”
Observed Behavior
Compliance argument rests on the position that IP addresses are not personal data and company identification falls outside GDPR. The CJEU has ruled otherwise (Breyer v. Germany). Addition of decision-maker contact data further challenges this claim. Awaiting scanner verification.
compliance
HIGH
They Claim
“Information provided is not relevant to GDPR legislation”
Observed Behavior
Platform provides individual decision-maker names and contact details linked to website visit behavior, which constitutes personal data processing under GDPR Article 4. Awaiting runtime verification of data collection scope.
data_collection
MEDIUM
They Claim
“Company-level identification only”
Observed Behavior
While initial IP resolution targets companies, the platform enriches with individual decision-maker contact information, crossing from company-level to individual-level identification. Awaiting scanner verification of JavaScript payload behavior.
Customer Impact
What This Means For You
Organizations whose employees visit sites running WhoIsVisiting face immediate competitive intelligence exposure. The platform reveals not just that a company visited, but which specific pages they viewed, how long they spent, and their browsing pattern — all mapped to the company name and enriched with decision-maker contact details. This is particularly damaging during vendor evaluation phases when research activity directly signals buying intent.
The white-label dimension compounds the risk: your employees may be tracked by WhoIsVisiting infrastructure deployed under completely different brand names, making it impossible to identify and block based on vendor name alone. From a regulatory standpoint, the vendor's aggressive interpretation of GDPR (that IP addresses are not personal data) creates liability transfer risk — if this interpretation is challenged, site operators using WhoIsVisiting bear the compliance consequences.
Recommended Actions
What To Do About It
Role-specific actions based on observed behavior
Recommended Actions for WhoIsVisiting
- →- Audit your web properties for WhoIsVisiting JavaScript snippets, including white-label variants - Assess competitive intelligence exposure by testing whether your company IP ranges are identifiable via reverse IP services - Evaluate the vendor's GDPR compliance claim against current CJEU rulings on IP addresses as personal data - Implement VPN or cloud browsing policies for employees conducting competitive research - Review data processing agreements for decision-maker contact data sourcing and retention terms
Negotiation Leverage
- →WhoIsVisiting's GDPR compliance argument is its primary vulnerability in negotiations. The claim that IP addresses are not personal data is legally contested, and the enrichment with decision-maker contact details undermines this position entirely. Use this as leverage to negotiate strict data processing agreements, consent-gating requirements, and data retention limits.
- →For procurement, demand transparency on the white-label program — specifically which third-party brands are deploying WhoIsVisiting infrastructure and whether data flows are shared across the white-label network. Require contractual guarantees on decision-maker contact data sourcing, including proof of lawful basis for processing. Negotiate audit rights and data deletion SLAs that cover both the primary WhoIsVisiting platform and any white-label instances where your visitor data may have been processed.
IOC Manifest
IOC Manifest
103 INDICATORS
Indicators of compromise across 3 categories. Use for detection rules, CSP policies, or Pi-hole blocklists.
TRACK
*www.whoisvisiting.com/wp-includes/js/jquery/jquery-migrate.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-includes/js/jquery/jquery.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-includes/js/dist/vendor/wp-polyfill.js*
Tracking script
TRACK
*dashboard.whoisvisiting.com/who.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/salient-social/js/salient-social.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/contact-form-7/includes/js/index.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.easing.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.mousewheel.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/priority.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/salient-portfolio/js/third-party/imagesLoaded.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/transit.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/waypoints.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/modernizr.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/hoverintent.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.fancybox.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/salient-portfolio/js/third-party/imagesloaded.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/third-party/superfish.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-includes/js/wp-embed.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/salient-core/js/third-party/touchswipe.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/plugins/js_composer_salient/assets/js/dist/js_composer_front.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-content/themes/salient/js/init.js*
Tracking script
TRACK
*www.whoisvisiting.com/wp-includes/js/wp-emoji-release.js*
Tracking script
TRACK
*app.whoisvisiting.com/who.js*
Tracking script
TRACK
www.whoisvisiting.com/wp-includes/js/jquery/jquery.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-includes/js/jquery/jquery-migrate.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-includes/js/dist/vendor/wp-polyfill.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/plugins/contact-form-7/includes/js/index.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/plugins/salient-social/js/salient-social.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.easing.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.mousewheel.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/priority.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/transit.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/waypoints.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/modernizr.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/plugins/salient-portfolio/js/third-party/imagesLoaded.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/hoverintent.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/jquery.fancybox.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/third-party/superfish.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/themes/salient/js/init.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/plugins/salient-core/js/third-party/touchswipe.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-includes/js/wp-embed.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-content/plugins/js_composer_salient/assets/js/dist/js_composer_front.min.js
Auto-extracted from scan
TRACK
www.whoisvisiting.com/wp-includes/js/wp-emoji-release.min.js
Auto-extracted from scan
TRACK
dashboard.whoisvisiting.com/who.js
Auto-extracted from scan
TRACK
app.whoisvisiting.com/who.js
Auto-extracted from scan
Ecosystem
Ecosystem & Supply Chain
WhoIsVisiting integrates with CRM platforms including HubSpot and Salesforce for automatic lead record creation when visitor companies are identified. The platform supports email alerts and custom trigger notifications to route leads to sales teams in real-time.
The white-label program is a significant ecosystem factor. WhoIsVisiting enables third-party resellers to deploy the same tracking infrastructure under different brand names, meaning the actual data collection footprint is larger than what is visible under the WhoIsVisiting brand alone. The underlying IP-to-company matching relies on proprietary databases that map IP address blocks (CIDR ranges) to registered organizations, with data sourced from ISP registrations, WHOIS records, and business data aggregators. Decision-maker contact data is sourced from separate business intelligence providers, creating a multi-layer data supply chain.
Evidence
Evidence Artifacts
Artifacts collected during analysis, available with evidence-tier access.
HAR Capture
Complete network capture with all requests and responses
IOC Manifest
103 detection signatures across scripts, domains, cookies, and network endpoints