There are a million variables. It depends on which settings you have enabled and if your key is near the car.
Do you have sentry mode enabled?
Do you have summon standby enabled?
Did you wake up the car, by checking the app for example, while it was parked?
Did cabin overhear protection kick in?
If you disable all of the above and keep your key a good distance from the car, you should expect at most a 1 mile/day loss.