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Comment: Actually, if you take the

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In reply to comment: It's Always Tracking You (see in situ)

Actually, if you take the

Actually, if you take the battery out of your smart phone then you cannot be tracked. (assuming the small amount of remaining internal energy is drained)

As for the disposable phones, same rules apply.
It is possible, even with burner phones, to listen in on the receiver/microphone, even if the phone is turned off. You have to take the battery out.