EDIT:
After looking at the connector with a endoscope's camera it turns out I've missed some pins. They are far less visible than other 8. The D+/D- and CC are there. This makes the example unsuitable. It still leaves the question of what spec allows open.

I've just bought a USB flash drive, a Kingston DataTraveler 70 (DT70/64GB).
Its Type C interface has only 8 pins:
A1 A2 A3 A4 A5 A6 A7 A8 A9 A10 A11 A12
NC NC NC NC NC NC NC NC PR PR PR PR
NC NC NC NC NC NC NC NC PR PR PR PR
B12 B11 B10 B9 B8 B7 B6 B5 B4 B3 B2 B1
NC = not connected
PR = present
The pins that are present are only GND, V+, and two SuperSpeed differential pairs.
There is no D+/D1 USB 2.x differential pair, and no CC1/CC2.
I've tried reading the spec for USB 3.2, but I couldn't find any passage that would clearly state USB 2.x lines are mandatory or optional for a device.
It's obviously terrible design for a USB flash drive not to support 2.x host, but is this legal from a specifications perspective?