The modal I have says exactly this:

--- Do you want to enable Dictation? When you dictate text, information like your voice input and contact names are sent to Apple to help your Mac recognise what you’re saying.

[Enable] Dictation Privacy (a policy) [Cancel] ---

I think it is entirely fair to put Apple in this category, because they have effectively disabled offline dictation for me except if I agree to sent my voice data to Apple. I have used this offline dictation feature for years by the way