On the one hand it wouldn't surprise me if the Qualcomm modem accesses the network on it's own - it very much wants to be a black box - on the other hand I doubt this story for two reasons:
- WiFi is implemented on the Android side. In all Android implementations I've seen, the WiFi module is part of the SoC or a separate chip, and Android runs the regular wpa_supplicant and so on. The chip cannot see the contents of packages, it only passes the bytes to the MAC (not sure if it is called that with WiFi).
(Now, of course in the case of a SoC the chip could, with driver support, peel back the encryption and inject it's own traffic, just like some IPMIs can share an ethernet connection with the OS. I just have not seen this yet.)
- In Android, it is usually the responsibility of the OS to fetch the AGPS data / almanach. You have a HAL consisting of a proprietary library (.so) that you get from the GPS vendor, some glue code, and a gps.conf. The gps.conf file lists the URLs to get the AGPS data. I'm not sure if the download is performed in the .so or in Java code, but anyway it is totally in the OS and not in the modem, at least in the cases I know. When a custom ROM, even a "degoogled" one, is made, you include a customized kernel and custom drivers, and the AGPS URLs are part of this "driver".