I think it depends. Sometimes LEDs are just used as a flash for the internal camera. They will probably have no heatsinking at all. If you hack these LEDs and use them constantly, they will probably get too hot because that's not what they are made for. I think most people don't consider that when they use some kind of a "flashlight-app". But there are also phones with a dedicated flashlight and since most of these flashlights have very little output, heatsinking is not that big a deal. A little piece of aluminium or copper will probably take up enough heat.