A tty can refer to a device name, or a physical terminal.
A terminal can refer to a physical or virtual terminal.
A console could also refer to a physical device, although I'm not aware of it being used in this context.
The problem is that computing is all metaphors. Metaphors leak and once we lose one meaning (enough) we stop clarifying to differentiate. We don't generally need to differentiate between a physical terminal and a virtual terminal, so we don't.
A tty can refer to a device name, or a physical terminal.
A terminal can refer to a physical or virtual terminal.
A console could also refer to a physical device, although I'm not aware of it being used in this context.
The problem is that computing is all metaphors. Metaphors leak and once we lose one meaning (enough) we stop clarifying to differentiate. We don't generally need to differentiate between a physical terminal and a virtual terminal, so we don't.