It will also do this even if you block the keyboard's internet access as it will use Google Play Services to send the telemetry data.
Previously discussed in this deleted reddit post: https://www.reddit.com/r/Android/comments/ymo3r9/deleted_by_...
At least turning off the "Share usage statistics" option in Gboard settings actually does opt you out...
> The telemetry sent by the Gboard application does not go directly to Google. Instead, the data goes through a service known as the Clearcut Logger within Google Play Services
To be fair, I have not tested whether Gboard continues to send telemetry to GPS even after networking is disabled on Gboard but there's nothing stopping that from happening from a technical perspective. This is because Android apps access GPS over Binder and Android apps can access Binder services even if they have no INTERNET permission.