Seems unlikely. They day I can’t wear my watch in the changing room is the day I stop wearing it to the gym, and therefore stop wearing it altogether, and therefore stop buying new ones every 5ish years.
In my experience, there is usually an obvious difference between seeing a phone used as a camera versus not, based on whether it's aimed at an interesting subject or not. There are exceptions, like sitting with your elbow propped on the arm of a chair for a few minutes to avoid fatigue, which causes the phone to be at eye level and therefore perfectly vertical, but this is rare.