I don't see what is so hard to understand.

One thing is internet connections that are initiated by user, or in the background from the apps that user voluntarily installed and wants to provide them a specific services.

Another thing is when a phone has a bunch of add-on adware (in some cases spyware) ,built-in into the phone, without user's knowledge, without user's consent and most of the time even ability to choose. Adware chosen by the manufacturer or provider, that is serving their purposes.

That is a clear existing distinction. It has nothing to do with being a smartphone or having an internet connection in general, or using a smartphone for internet-related tasks.