The Holding · Legal
Legal & Jurisdictional Notice
Privacy · Cookies · Terms of Engagement · Jurisdictional Notice.
The provisions below govern access to and use of this site and the contractual relationship between the holding and its institutional clients. Last updated May 2026.
01
Privacy Policy
In accordance with Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003 as amended.
1. Data Controller
The data controller is Costantini & Partners, an independent advisory and technology holding registered in Italy under VAT identification IT 03923370542. Contact for data-protection enquiries: privacy@costantinilawfirm.capital.
2. Categories of Data Processed
The holding processes the following categories of personal data:
- Identification data — name, organisation, professional title
- Contact data — email address, professional telephone number
- Brief content — the information voluntarily submitted in the contact form, including the description of the prospective mandate
- Technical data — IP address, browser identifier, session telemetry strictly necessary for site security and integrity
The holding does not process special categories of personal data (Article 9 GDPR) through this site. Should the substance of an engagement require such processing, it will be regulated by a separate data-processing agreement.
3. Lawful Basis & Purposes
- Pre-contractual measures (Art. 6(1)(b) GDPR) — evaluation of submitted briefs and any subsequent scoping conversations.
- Legitimate interests (Art. 6(1)(f) GDPR) — site security, fraud prevention, and the integrity of the holding’s communications. The legitimate-interest assessment is available on request.
- Consent (Art. 6(1)(a) GDPR) — only where you have affirmatively consented, e.g. to non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
- Legal obligation (Art. 6(1)(c) GDPR) — tax, accounting, and regulatory record-keeping obligations applicable to the holding under Italian and EU law.
4. Retention
Brief submissions that do not result in an engagement are retained for a maximum of twenty-four months from receipt and are then deleted or anonymised. Records relating to actual engagements are retained for the period required by applicable law and the relevant statute of limitations, typically ten years from the conclusion of the mandate. Site-security telemetry is retained for a maximum of twelve months.
5. Recipients & Cross-border Transfers
Personal data may be processed by the holding’s data processors (responsabili del trattamento) appointed under Article 28 GDPR — including the hosting provider, email infrastructure provider, and professional advisors bound by confidentiality. The holding does not sell personal data to third parties.
Where personal data is transferred outside the European Economic Area, the transfer is governed by an adequacy decision under Article 45 GDPR, by Standard Contractual Clauses (Decision (EU) 2021/914) under Article 46 GDPR, or by another lawful transfer instrument. A list of relevant transfers is available on written request.
WhatsApp Business communications. Where a data subject contacts the holding via WhatsApp Business at +39 379 365 3120, the messaging service is operated by WhatsApp Ireland Ltd (Meta Platforms Inc., 4 Grand Canal Square, Dublin 2, Ireland), which acts as an independent data controller for the platform under its own Privacy Policy and Terms of Service. The holding acts as a separate, independent data controller for the substance of communications received, which it processes under Article 6(1)(b) GDPR (pre-contractual measures and contract performance) and retains under the same retention periods stated in section 4 above.
Cross-border transfers of personal data through the WhatsApp service occur outside the European Economic Area and are governed by WhatsApp’s own transfer mechanisms (Standard Contractual Clauses under Article 46 GDPR; adequacy decisions under Article 45 GDPR where applicable). The holding itself does not transfer the substance of WhatsApp communications to any additional recipient outside its appointed processors. Data subjects who prefer to avoid third-party messaging processors may contact the holding exclusively via email at managing.partner@costantinilawfirm.capital, which is hosted on controlled corporate infrastructure under the holding’s direct data-protection responsibility.
6. Rights of the Data Subject
You may exercise the rights provided by Articles 15–22 GDPR, including access, rectification, erasure, restriction of processing, portability, and objection. Requests should be addressed to privacy@costantinilawfirm.capital. The holding will respond within thirty days.
You also have the right to lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it) or with the supervisory authority of your habitual residence.
02
Cookie Policy
In accordance with the Italian Garante guidelines of 10 June 2021 and the ePrivacy Directive.
1. What is a cookie
A cookie is a small text file that a website may place on the user’s device to recognise it, remember preferences, and collect usage statistics. Equivalent technologies include local storage, session storage, and pixel tags; the term “cookie” in this policy covers all such technologies.
2. Cookies and Equivalent Technologies in use
This site uses two categories of cookies and equivalent technologies, both of which qualify as either strictly necessary or technical analytics (first-party, non-profiling) under the Garante guidelines of 10 June 2021 and Article 122 of the Italian Privacy Code, and therefore do not require prior consent.
(a) Strictly necessary cookies and tokens. Required for site functioning and security. Examples: session continuity for the contact form, anti-CSRF tokens, security challenge cookies set by the hosting provider (Netlify). Lifespan: session.
(b) First-party technical analytics — Perseus CP. The
site operates a proprietary, first-party analytics system named
Perseus CP, used solely to measure aggregate site performance (pageviews,
session counts, scroll depth, click events). Perseus CP stores two random
identifiers in the visitor’s browser localStorage:
_cp_visitor (persistent, used to count unique visitors) and
_cp_session (30-minute sliding window). Telemetry is sent
exclusively to /api/track on this domain. No data is shared
with third parties; no Meta Pixel, Google Analytics, TikTok Pixel or
other third-party tracker is loaded. Server-side, the visitor IP is anonymised
(last octet zeroed for IPv4) before storage. Bot user-agents and visitors with
Do-Not-Track enabled are excluded. Lifespan of _cp_visitor:
up to twelve months.
Under the Garante guidelines of 10 June 2021 (paragraphs 7.2–7.3),
first-party analytics with no profiling, no third-party data sharing, IP
minimisation, and no cross-site tracking is treated equivalent to a technical
cookie and may be deployed without prior consent. The data subject may
nonetheless opt out at any time by clearing their browser’s
localStorage for costantinilawfirm.capital, by enabling
their browser’s “Do Not Track” signal, or by emailing
privacy@costantinilawfirm.capital.
3. Non-essential cookies
No non-essential cookies are currently deployed. Should the holding in the future deploy cookies or technologies that do require consent under Italian and EU law (e.g. profiling cookies, third-party tracking, advertising cookies), this policy will be updated and a consent banner will be introduced in compliance with the Garante guidelines. Until then, no consent banner is displayed.
4. How to manage cookies
All major browsers allow the user to control, block, or delete cookies through their settings. Disabling strictly necessary cookies may impair the functioning of the contact form. Useful references:
03
Terms of Engagement
Conditions governing access to this site and the formation of engagements.
1. Information Purpose
The content of this site is provided for general informational purposes and does not constitute legal, tax, financial, or investment advice. Nothing on this site is intended to create a contractual or fiduciary relationship between the holding and the visitor. Engagements are formed exclusively through written bilateral contracts executed between the holding and the client.
2. Brief Submission
Submission of a brief through the contact form does not bind the holding to accept the engagement. Briefs are evaluated within five business days. The holding reserves the right to decline any brief without obligation to state reasons. Acceptance of a brief opens a scoping conversation, the conclusions of which are recorded in a scoping memo. Acceptance of a mandate is conditional on the execution of a bilateral engagement contract.
3. Confidentiality
All communications, briefs, and engagement materials are treated under confidentiality. The holding observes strict separation between concurrent engagements and refuses any mandate that would create a conflict of interest with an existing client.
4. Intellectual Property
All trademarks, logos, copy, code, and proprietary frameworks made accessible on this site — including the names Costantini & Partners, Consistory, The Magisterium, Mirafiore Editore, Parsifal, Maestro, Parsifal WA, Perseus, Hans Sachs, and the Verdi·Nabucco·Omero operating layer — are the property of the holding. No licence or right of use is granted by access to the site.
5. Scope of Services
The holding operates as a Law Firm in the international sense, providing exclusively unreserved high-level strategic, regulatory, and technological consulting to corporates and family offices across multiple jurisdictions. The holding deliberately does not engage in domestic litigation or adversarial representation, preserving total operational independence and cross-border flexibility. All engagements are documented under bilateral corporate contracts.
6. Limitation of Liability
To the maximum extent permitted by applicable law, the holding accepts no liability for direct or indirect loss arising from the use of information contained on this site outside the perimeter of an executed engagement contract. Within an engagement, liability is governed by the bilateral contract and any limitation clauses contained therein.
7. Modifications
These terms may be modified from time to time. The version in force is the one accessible on this site at the time of access. Material modifications will be notified to active engagement clients in advance.
04
Jurisdictional Notice
Governing law, applicable forum, and the holding’s position toward territorial regulatory authorities.
1. Governing Law
Use of this site is governed by Italian law. Engagement contracts may select a different governing law in the bilateral contract; in the absence of such selection, Italian law applies.
2. Forum
Disputes arising from the use of this site — outside of any executed engagement contract — are subject to the exclusive jurisdiction of the Court of Perugia, Italy. Engagement contracts may select a different forum or arbitration seat in the bilateral contract.
3. Holding Posture toward Territorial Authorities
Costantini & Partners operates globally as an elite holding for corporate advisory and strategic intelligence. To maintain our total operational independence across multiple jurisdictions, we provide exclusively unreserved high-level strategic, regulatory, and technological consulting. We choose not to engage in domestic litigation, and we operate deliberately as a Law Firm. All cross-border engagements are governed by bilateral corporate contracts. We construct strategies of power; we do not provide ordinary legal representation.
4. AI & Algorithmic Transparency
This site does not deploy AI-driven decision-making, profiling, or automated individual decisions affecting visitors within the meaning of Article 22 GDPR. Where AI-assisted tooling is used internally to draft, summarise, or translate, the substantive editorial responsibility remains with the Managing Partner.
5. Contact
For legal correspondence:
legal@costantinilawfirm.capital.
For data-protection enquiries:
privacy@costantinilawfirm.capital.
For mandate enquiries:
managing.partner@costantinilawfirm.capital
+39 379 365 3120.