[itaxim]

Alternatively, it may not have been icloud that was hacked at all. Dropbox would probably have more private photos than even icloud because often when people delete a picture it's already uploaded to the Camera uploads folder. Not many people wade through their camera uploads folder weeding out unsavoury pics.

This would explain why a lot of the phones in question were Android. Dropbox comes preloaded on most samsung phones, and gives you heaps of data. Willing to bet most people who don't know what they are doing automatically accept Camera Uploads.