I think there is a bit of over analysis here.
Surely the answer is "no".
Without even technically analysing this from a legal perspective , look at it from the customer perspective.
If I follow a company on Twitter I understand that their tweets may contain advertising material. I also if I think hard about it understand there may be circumstances in which they may be (just) be justified in sending me a DM. I do not however expect them to direct advertising to ME specifically, and its highly doubtful if I will ever read any of their T&Cs.
It would not be in my reasonable expectation. I expect if they want to "sell" something they will publish a tweet - which I will see.
In any event I am satisfied it falls outside R22.
PS Does the soft opt-in even exist given the stringent requirements of fairness at point of collection?
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