So if you're worried about NSA or the like - you better not have a mobile phone/device (or a car - because new cars sold in EU all have eSIM for builtin emergency calls) at all.
And for particular first hand example - Xplora smart watch/phone got super confused when my kids school physically moved.
New building has indoor sports/gym (I think it's basketball court size) on the top floor - and all the reinforced concrete means mobile reception can be hit and miss (even on 3/4G).
Despite phone/watch never connecting to school (staff only) wifi. After move to new building - watch and parent app would regularly think/bounce location between old and new school buildings.
When even 3rd party companies have a mapping between wifi/ssid and approximate geo location, you can imagine state sponsored actors have at least next order of magnitude.