My friend keeps her phone in a purse, which she puts on the floor of the passenger side whether she is driving or a passenger sitting shotgun. It’s always in the same place. When we take Ubers she usually sits in the middle so she can see, and puts the purse between her feet. Thus her phone is almost never on her person in the car.
I suspect this is true for a lot of people who use purses or other bags as every day carry. Or perhaps it’s actually in the passenger seat, lots of people use that for bags when driving solo.
So while it may be true for you that your phone is on you while a passenger, that’s a ton of people it isn’t true for at all, who would then be in the “bad data” camp.