Well there's the disingenuous way in which they present the choice, defaulted to opt in with flowery language, versus the popup third party developers have presented to their users.
There's also the "app store health card" which the cynic in me would say is designed to scare people away from "competing" apps, because none of the Apple equivalents have a health card. Additionally there's no nuance - both iMessage and Twitter ask for location data - but only if you want to share your location. End result? People looking at Twitter in the App Store surmise "well, they must be tracking my location at all times!".
Built in apps - iMessage. And yes, that does seem to be in the app store now, however, there's a lot there that seems to be missing - access to photos for example isn't listed in the health card, neither is microphone access - both of which are core features of the app.
It looks like the way it's implemented, access to photos comes through a Photos extension to iMessage (I think I recall these being called "iMessage apps"?), rather than it being inherent to the app.
And options for the microphone similarly seem to belong either to the extensions, or to the system—which handles microphone input as a substitute for typing.
It's possible you're right, and I'm missing something, but that's how it appears to me.
Is that available to other apps? If not - then this just looks like they're skirting around things they foist on third party developers to make themselves look squeaky clean.
(I’m not a fan of ads, but don’t see how this is necessarily a privacy issue)