23Sha-ger
I don't think this is quite right. Even without a SIM card, your phone will be in periodic contact with the various cell networks. The phone's IMEI is a persistent unique identified that will be collected. Even if it wasn't tied to you at purchase, a few timestamped coarse locations from cell trilateration (say, home, work, airport) are likely sufficient to identify you.
From the cell tracking FAQ:
Airplane mode is the only way to avoid the cellular network tracking your device and works correctly on the devices we support.