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Yes, these are obviously not 'on-campus' in the strict sense, but are the regular exam format the university has chosen, so technically count as 'on-campus'. It's obviously not very good terminology. What is usually meant by 'off-campus' are irregular exam formats like those taken by candidates who can't travel from where they are for good reasons and often take theirs in locations like embassies or local universities and the like. They're usually difficult to organise and not uncommonly take several attempts to actually happen.
Or even just UoL (e.g. UCL) students taking exams at Excel London, not exactly part of campus.