And anyone who is likely to be tracked is going to know this, and will not trust phone communications. The more you have to hide, the more protections you must

And anyone who is likely to be tracked is going to know this, and will not trust phone communications. The more you have to hide, the more protections you must take. You cannot rely on technology. In extreme cases, it means eschewing technology entirely, living in caves, and living in Afghanistan and Sudan. You cannot rely on that which you do not control, including free software.