Except that the word, "recall", doesn't have two different meanings. It literally means the same thing here as it does for a recall wherein a Jeep has to have its shifter replaced / tweaked / whatever.

Just so happens that the latter can't be fixed via software, because it's not a software-based safety failure.

The former is fixable via software update, because it is a software-based safety failure.

Both, however, are safety failures. Both need to be fixed. Both situations incurred regulatory requirements to notify customers and provide a timely fix at no cost to affected customers, whether within or without the vehicle's warranty.

In short: both are recalls, and recall means the same thing in both cases: notify, fix, or face regulatory consequences.