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Untrackable phones refer to the phone’s ability to hide its real geo-location by showing its location in a different place than where the phone actually is. Some kids’ apps available on Google Play Store or Apple Store use third-party data connections and servers and display a fake GPS location in another part of the world, which is not only stupid but also dangerous when it comes to law enforcement:

You can’t trick authorities with this kind of apps, because the real GSM location used by law enforcement to track a cell phone will reveal their real location despite VPN.

Conceptually, location tracking is usually misunderstood or confused with GPS location tracking:

• Cell phones are not tracked by the built-in GPS module unless a spyware app installed on the respective phone collects and sends GPS data to a server where it can be viewed by attackers.
• The GPS module does not transmit a signal. A GPS module is merely a radio receiver, like your radio. A radio receiver cannot be tracked, of course, because it is a completely passive device. The same is true for your cell phone’s GPS module. Sure, a cell phone GPS feeds location data to some other apps you have installed on your phone, apps that can be exploited remotely to spy on your GPS location data. But in real life, this doesn’t happen too often as very few actors like NSA have this privilege.
• Some big marketing companies also use some tracking apps that phone users install on their own phones (location-based services), or they distribute cloaked apps (similar to malware) that collect location information from the user’s phone along with other data.
• There are many cell phones that do not have a GPS function (no GPS module). But that doesn’t mean that these cell phones can’t be tracked. Mobile location tracking was not born in the same time as smartphones, as they are as old as cell phones themselves. In most countries, if a silent phone cannot be tracked, it is immediately banned from sale and use for obvious reasons.