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Re:Tim Cook makes blistering attack on the “data industrial ... by macintux on Wednesday October 24, 2018 @11:16AM (#18293143)
I don't allow anything Facebook-owned to access my location, so I can't speak to Messenger, but perhaps FB simply doesn't want you to lose location sharing if iOS has to kill Messenger while running in the background.

Always: an app can always access your location

While using: an app can access your location until explicitly terminated by the user or the OS due to resource constraints

Never: self-evident

Re:Tim Cook makes blistering attack on the “data industrial ... by Tehnix on Wednesday October 24, 2018 @11:24AM (#18293205)
Fair enough, I seemed to have missed the background part from

> An app is considered "in use" when you're actively using it in the foreground, or when it's in use in the background, which the status bar will indicate.

from https://support.apple.com/en-us/HT203033. There is still the indication, but admittedly that is not the same.