Why would they waste their time on Bluetooth tracking when your location pings cell towers and WiFi hotspots?
Now consider the vast number of “smart nodes” out there (eg street lights) that have multi-protocol connectivity built into them. Whoever controls these nodes can simply scan and log every BLE advertisement that is nearby.
I’m not saying that this is the only way that a person can tracked or that this kind of tracking is definitely happening right now, but it’s a very real possibility.
UWB and Cell tower tracking are much more accurate for the majority of real-world applications