this depends on your definition of pay to win itself, as a looter shooter, the loop of the game is
kill mob-->gain loot -->repeat
there is no win condition in destiny 2, which means by definition you can not have pay to win.
However that changes if your win condition is gaining loot.
If my win condition is gaining better loot, then speeding up the acquisition of loot is by definition paying to win.
You can sit there and say there is no pay to win by definition, but by the same metric, nearly all mobile games sit in the no pay to win category as well.
It's a slippery slope, and saying "Paying to skip content or getting preorder bonuses isn’t pay to win." is no different than saying "My father gave me a small loan of a million dollars".
Technically both true to the person speaking, but to the rest of us, not so much.