By Christine Desrosiers, VP of Product, Head of Privacy, Boltive
Here’s the thing about privacy and security in digital advertising right now: We’re all staring at a tsunami, and most of us are still arguing about whether we need an umbrella.
For privacy and security teams in the ad industry, the writing on the wall is pretty clear – the risk is accelerating at a pace that’s leaving our current strategies in the dust. And here’s what keeps me up at night: While everyone’s still obsessing over web cookies and third-party deprecation, the real danger is quietly building in places most teams aren’t even watching. I’m talking about in-app and Connected TV (CTV).
Let me be blunt: The web cookie drama? That was our warm-up lap. The privacy and security challenges emerging in in-app and CTV environments are going to evolve exponentially faster than anything we experienced during the decade-long cookie saga. These environments are more complex, more fragmented, and moving at a velocity that makes the web’s evolution look glacial by comparison.
The AI-Driven Acceleration Nobody’s Talking About
Add AI into the mix, and we’re facing something entirely different. AI-driven traffic and behavioral changes are reshaping the digital landscape at speeds we’ve never seen before. Automated systems are making real-time optimization decisions, creative is being generated and deployed on the fly, and user interactions are being analyzed and responded to in milliseconds.
This isn’t theoretical – it’s happening right now. And it’s creating an environment where privacy controls can break faster than teams can detect them, let alone fix them. Without active, continuous monitoring, even well-configured systems drift. What was compliant yesterday might be a regulatory time bomb today.
Why In-App and CTV Are Different (and More Dangerous)
The industry spent years wrestling with web-based tracking and cookies. We developed CMPs, we implemented consent frameworks, we built entire compliance infrastructures. And yet most organizations are treating in-app and CTV like they’re just another channel to check off the list. They’re not.
In-app and CTV environments operate fundamentally differently:
- Fragmentation is extreme: Thousands of apps, hundreds of CTV platforms, each with their own SDKs, frameworks, and data flows
- Visibility is minimal: Unlike the web where you can inspect page source, in-app and CTV tracking happens in black boxes
- Change happens constantly: App updates, SDK changes, server-side modifications – all invisible to traditional monitoring
- The stakes are higher: These environments collect more sensitive data, often with less user visibility or control
And here’s the kicker: The technology governing privacy in these spaces is evolving at breakneck speed – years faster than the web’s trajectory. We won’t have the luxury of a slow, methodical crawl through standards and frameworks. The change is happening now, and it’s happening fast.
The Four Patterns That Will Become Tomorrow’s Headlines
We’re seeing clear risk patterns emerging across organizations of every size. These aren’t edge cases – they’re systematic failures waiting to become public disasters:
- Consent Signal Failure: Your CMP captures the user’s choice perfectly. Great. But does that signal actually make it to every downstream ad system, SDK, and partner in real-time? We’re seeing consent signals break in translation constantly – especially in in-app and CTV where the technical implementation is far more complex than dropping a web tag.
- Persistent Tracking Post-Opt-Out: A user opts out. Your systems acknowledge it. But pixels keep firing, identifiers keep getting passed, SDKs keep collecting. Even one misfiring vendor creates material legal exposure. In AI-optimized environments where systems are making autonomous decisions, these failures can propagate across your entire ecosystem before you know they exist.
- Unauthorized Downstream Sharing: Your approved vendor list looks clean. But your vendors have their own vendors. And those vendors have partners. And somewhere down that chain, data you thought was controlled is flowing to entities you’ve never heard of. This shadow data supply chain is especially problematic in CTV, where server-side connections make tracking these relationships nearly impossible with traditional tools.
- Ad-Triggered Data Leakage: Your creative runs on a third-party site or in an app. Embedded in that creative are pixels or SDKs that activate without your knowledge, triggering data collection you never authorized. AI-generated creative makes this exponentially worse – automated systems can inject tracking mechanisms that bypass your approval workflows entirely.
These patterns aren’t the result of malicious actors. They’re the natural consequence of complex, interconnected ecosystems evolving faster than governance can keep pace. Static, point-in-time audits miss them entirely.
What Actually Works
The solution isn’t another checklist or another quarterly audit. It’s a fundamental shift in how we think about compliance monitoring.
Privacy and security teams need systems that provide real-time visibility into actual behaviors across the entire digital supply chain – especially in the in-app and CTV environments where risk is accelerating fastest. Effective data privacy monitoring goes beyond basic CMP checks; it involves simulating real user journeys, continuously monitoring for failures, tracking the full data chain through all vendors and partners, and adapting in real-time as AI systems modify traffic and targeting.
This is especially critical for in-app and CTV, where the technical complexity and rate of change make traditional monitoring approaches essentially useless. You can’t inspect what you can’t see, and you can’t audit what changes hourly.
2026 Reality Check
Here’s what I know: The organizations that treat this as just another compliance box to check are the ones we’ll be reading about in headlines. The teams that recognize we’re in a fundamentally different environment – one shaped by AI-driven acceleration and the explosive complexity of in-app and CTV – are the ones that will maintain consumer trust and avoid regulatory disaster.
Static privacy compliance is obsolete. Unlike the slow evolution of web cookie changes, in-app and CTV environments are moving too fast, are too complex, and have stakes too high for traditional methods to keep up.
The question isn’t whether your privacy controls will drift or break. In a dynamic, AI-accelerated environment, they absolutely will. The question is whether you’ll know about it in time to do something about it – or whether you’ll find out when the regulator or the headline arrives.
We can’t stop the tsunami. But we can stop pretending an umbrella will be enough.
