Criminals often use burner phones, these phones often are built with easier data retrieval methods, due to the lack of security software included. Modern Android phones, will have the latest Android Security patch, they also feature things like onboard encryption (especially Samsung phones).
It is when an internet user, with malicious intent discovers information about you and uses it in a negative way, often adding their own opinion or taking things out of context. They use this to potentially stalk or drive their victim offline.