Cookie Policy
The Thunder Trader
Last updated: 25 May 2026
Table of Contents
- Introduction
- What cookies and other identifiers are
- Categories of cookies used
- Detailed list of cookies
- Third-party cookies and transfers outside the EEA
- Legal basis and retention period
- How to manage cookie preferences
- How to disable cookies from the browser
- Consequences of refusal
- Changes to this Cookie Policy
- Contacts
1. Introduction
This Cookie Policy describes the types of cookies and other tracking tools used on the website thethundertrader.com and on the The Thunder Trader platform subdomains (dashboard, trading, historical, checkout), as well as the ways in which the user can manage their preferences.
This document supplements the Privacy Policy and is drafted in compliance with:
- Regulation (EU) 2016/679 (GDPR)
- Directive 2002/58/EC as amended by Directive 2009/136/EC (ePrivacy Directive)
- the Italian Data Protection Authority Order of 10 June 2021 “Guidelines on cookies and other tracking tools”
Data Controller: LN17 ShapeFuture Limited, Flat D, 20/F, Eton Building, 288 Des Voeux Road Central, Sheung Wan, Hong Kong (CR No. 80441068). Contact email: legal@thethundertrader.com.
2. What cookies and other identifiers are
Cookies are small text files that visited websites send to the user’s device (computer, tablet, smartphone), where they are stored to be retransmitted to the site at the next visit. Cookies allow the user’s device to be recognised, certain information about visits to be recorded, and essential or additional functionalities to be provided.
In addition to cookies, there are other tracking technologies that the Controller may use and that are treated in this Policy with the same safeguards provided for cookies:
- Local storage and session storage (local storage in the browser)
- Tracking pixels (web beacons, transparent images)
- Fingerprinting (device recognition through the combination of parameters)
- Third-party SDKs integrated into the platform
For simplicity, the term “cookies” in the rest of this document refers to all the tracking tools listed above, unless otherwise specified.
3. Categories of cookies used
The site uses three categories of cookies, according to the classification of the Italian Data Protection Authority:
3.1 Technical cookies (essential)
Cookies strictly necessary for the operation of the site and the provision of the service requested by the user. They include:
- Navigation and session cookies: keep the user session active, manage the cart and purchase flow, maintain login in the reserved area
- Functionality cookies: store preferences such as site language, displayed theme, acceptance of the cookie banner
- Security cookies: protection against automated attacks (technical CAPTCHA), detection of session anomalies, two-factor authentication
- Load balancing cookies: distribution of traffic across platform servers
Legal basis: legitimate interest of the Controller in providing the service (Art. 6.1.f GDPR). Such cookies do not require the user’s prior consent under Art. 122 of the Italian Privacy Code.
3.2 Analytics cookies
Cookies used to collect information in aggregate form on the number of users and how they visit the site. The Controller uses exclusively third-party analytics cookies (Google Analytics 4) configured with the following mitigation measures provided for by the Italian Authority’s Order:
- IP address anonymisation (IP masking)
- Disabling of data sharing with other Google services for profiling and advertising purposes
- No data enrichment with information from third-party sources
- Maximum retention period of 14 months
In consideration of these measures, Google Analytics 4 is equivalent to a first-party analytics cookie under the Order. However, for greater user protection, prior consent is still requested through the cookie banner at the site’s entry.
Legal basis: user consent (Art. 6.1.a GDPR; Art. 122 Italian Privacy Code).
3.3 Profiling and marketing cookies
Cookies used to build a profile of the user based on their browsing habits, in order to send advertising messages in line with their interests.
Current status: the Controller does not use profiling cookies or behavioural marketing cookies on the site. Should they be introduced in the future, this Policy will be updated and the user will be asked for new explicit consent through an updated banner.
4. Detailed list of cookies
The following table lists the cookies actually active on the site at the time of the last update of this Policy.
4.1 Technical cookies
| Name | Provider | Purpose | Duration |
|---|---|---|---|
wordpress_logged_in_* | thethundertrader.com (first party) | Maintenance of the login session in the reserved area | Session |
wp-settings-* | thethundertrader.com (first party) | Storage of user interface preferences | 1 year |
trp-form-language | thethundertrader.com (first party) | Storage of the language selected by the user (TranslatePress) | Session |
tt_cookie_consent | thethundertrader.com (first party) | Storage of user preferences expressed in the cookie banner | 6 months |
tt_session_id | thethundertrader.com (first party) | Technical session identifier for the platform | Session |
tt_2fa_token | thethundertrader.com (first party) | Temporary token for two-factor authentication | 10 minutes |
4.2 Analytics cookies (upon consent)
| Name | Provider | Purpose | Duration |
|---|---|---|---|
_ga | Google Ireland Limited | Unique identification of users for aggregate statistics | 13 months |
_ga_<container-id> | Google Ireland Limited | Persistence of the Google Analytics 4 session state | 13 months |
Data collected by Google Analytics 4 is retained for a maximum of 14 months and is automatically deleted upon expiry.
4.3 Operational cookies of the simulated trading platform (upon consent or legitimate interest)
For registered users accessing the participation platform for Performance Arena Event, additional technical operational cookies may be activated, managed by the infrastructure provider Volumetrica FX / Trade Tech Solutions, exclusively aimed at the operation of the simulated trading environment. These cookies qualify as technical and do not require additional consent beyond what is provided for in the acceptance of the Terms of Service.
5. Third-party cookies and transfers outside the EEA
Some cookies are installed by third parties acting as data processors or autonomous controllers. For third-party cookies, the user is invited to also consult the privacy policies of the respective providers, indicated below.
| Third party | Type | Privacy Policy | Data transfer |
|---|---|---|---|
| Google Ireland Limited (Google Analytics 4) | Analytics | https://policies.google.com/privacy | Data processed primarily in the EU; any transfers to the United States take place under the EU-U.S. Data Privacy Framework (DPF) |
In the event of future introduction of additional third-party services (e.g. support chat, social plugins, embedded videos), this table will be updated and the user will be asked for new consent where necessary.
For the safeguards applied to data transfers outside the European Economic Area, please refer to Section 9 of the Privacy Policy.
6. Legal basis and retention period
| Type | Legal basis | Retention |
|---|---|---|
| Technical cookies | Legitimate interest (Art. 6.1.f GDPR) and technical necessity (Art. 122 Italian Privacy Code) | Variable, from session duration to a maximum of 12 months |
| Analytics cookies | Consent (Art. 6.1.a GDPR; Art. 122 Italian Privacy Code) | Maximum 14 months |
| Profiling cookies | Consent (Art. 6.1.a GDPR) | Not used at present |
The consent given by the user in the cookie banner has a maximum duration of 6 months, in compliance with the Italian Authority’s Order. Once such period has elapsed, the banner will be presented again to the user for the renewed collection of consent.
The refusal of consent is also stored to prevent the banner from being presented again at each visit; in such case, the technical cookie tt_cookie_consent will record the user’s choice.
7. How to manage cookie preferences
The user can manage their cookie preferences at any time through the following tools:
7.1 Cookie banner
Upon first access to the site, a banner is presented allowing the user to:
- Accept all cookies (technical + analytics)
- Reject all cookies that are not strictly necessary (keeping only technical ones active)
- Customise preferences, choosing the individual categories to accept or reject
The reject button and the accept button have equal graphic prominence, in compliance with the Italian Authority’s indications.
7.2 Modify preferences at any time
The user can modify previously made choices at any time through:
- the “Manage cookie preferences” link available in the footer of every page of the site
- manual deletion of the
tt_cookie_consentcookie from the browser (in such case the banner will be presented again on the next access)
7.3 Storage of expressed choices
The choices expressed by the user in the banner are stored as a technical cookie for a period of 6 months. Once such term has elapsed, the banner will be presented again to allow the user to confirm or modify their preferences.
8. How to disable cookies from the browser
In addition to the tools made available by the site, the user can configure their browser to accept, reject or delete cookies at any time. Operating instructions vary from browser to browser; below are the links to the official support pages:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Safari (desktop): https://support.apple.com/guide/safari/sfri11471/mac
- Safari (iOS): https://support.apple.com/HT201265
- Microsoft Edge: https://support.microsoft.com/microsoft-edge
- Opera: https://help.opera.com/en/latest/web-preferences/
To specifically disable Google Analytics cookies across all sites, the official browser add-on is available at: https://tools.google.com/dlpage/gaoptout
9. Consequences of refusal
The refusal of cookies has differentiated consequences depending on the type:
- Refusal of technical cookies: not possible, as technical cookies are strictly necessary for the operation of the site. Manual disabling through the browser may compromise or prevent navigation, access to the reserved area, use of the participation platform for Performance Arena Event
- Refusal of analytics cookies: no consequences on browsing. The Controller will not be able to collect aggregate statistics on the user’s use of the site
- Refusal of profiling cookies: not applicable (not currently used)
10. Changes to this Cookie Policy
The Controller reserves the right to modify this Cookie Policy at any time to adapt it to:
- regulatory developments
- introduction of new technical tools or third parties
- recommendations from the Italian Authority or other supervisory authorities
In case of substantial modifications, in particular the introduction of profiling cookies or new third-party cookies, the banner will be presented again to the user for the collection of updated consent.
The date of the last update is indicated at the beginning of this Policy.
11. Contacts
For any request concerning the processing of personal data through cookies, the user can write to:
legal@thethundertrader.com
For any matter not specifically governed by this Policy, please refer to the full Privacy Policy, available at the link in the footer of the site.
The user also has the right to lodge a complaint with the Italian Data Protection Authority – Garante per la protezione dei dati personali (Piazza Venezia 11, 00187 Rome, Italy; www.garanteprivacy.it) or with the supervisory authority of their EU Member State of residence.
Document drafted in compliance with Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC (ePrivacy) as amended by Directive 2009/136/EC, the Italian Data Protection Authority Order of 10 June 2021 “Guidelines on cookies and other tracking tools”.