I think it depends on the shape of the ear nozzle on the earphones.
I've had a couple of pairs of wireless earphones with wings and hooks and they still don't stay in
There are some that are just well designed in their shape and stay in
The new Samsung buds are an example of this, best fit I've had yet with a wireless earphone.
For most of my listening I use my K10U/ZX507 wired (or with SE846 with BTR5 via LDAC) but when out cycling/walking etc. I use a cheap set of Samsung Buds+ with S10+ and in addition to sounding great for their price they are never in danger of falling out. Its like twist & lock in your lobe with the little rubber tab ring thing.
If a bud hasn't got LDAC (or the Samsung Propriety BT with my S10+ sounds good too) I won't consider them. Nothing sounds as good wireless as my BTR5 using LDAC via balanced with quality IEM.
You do need the right tips for your ears too, to keep the suction type effect. The Buds+ had a default silicon tip that do that perfectly for my ear shape.
I can feel my ear hairs pushing the ear buds out (age 51), doesn't matter if I use large medium small, comfort, silicon, foam notthing stays in unless they have wings. Tried about 6 pairs over the years, the last non-wings ones were Jabra 65T lasted less than a week before they had to go back.
Mine arrived today, obviously bedding in but early impressions are these are great, lovely premium feel, sit nicely in the ears and the ANC and sound quality is I would say in the top tier for this price range (for IEM's)