Possible to negotiate PTO?

I have an offer from Apple and noticed their PTO policy is 12 days for the first 3 years. They claim to give 2 weeks off for Xmas / NYE but really it’s 3 days discounting the holidays everyone gives.

Given that I’m getting 23 days a year, giving up 30 days of saved PTO, and 30 day recharge that would be coming up, 12 days seems crazy low to me.

Based on the comp numbers, they’ve indicated willingness to negotiate on non-comp items. Anyone have knowledge if PTO is on the table at all?

Blind-tax ~400k