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Isn't that true for just about every storage device? I think the issue is when you erase the storage media, traces of the files can be recovered from the storage. This is true for your phone and also your personal computer. If you formatted your hard drive, someone could still use a data recovery to recover your data. Short of totally destroying your physical media, there may be no 100% way of erasing all data. The realistic goal would be erasing the data to the point where an average person can't recover it.
Based on what I read from the article, the issue is that if you erase your phone, the data can still be recovered from the phone using off-the shelve tool. Apple is a bit better since later generation of iphone handles encryption better. If you want to avoid this situation, look into an android phone with encryption features.
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