About 6 years ago as little as 5% of smartphones permanently had their GPS ‘on’. Today, because of thousands (if not hundred of thousands) of apps in use (which require GPS to be on), estimates and research suggest this percentage to be in the high 90’s (%).
This means a large portion of consumers have their GPS permanently on and with that, their exact location can be determined. This can be as accurate as 5 meters. It’s worth mentioning that, although developments are being made for the mobile-web protocol, only an ad-request coming from within an app - can ‘transfer’ a GPS position (or; latitude/longitude coordinates).