The initials "EEPROM" stand for Electrically-Erasable PROM

So, literally speaking, it is correct to say that "Flash" is "EEPROM" - it is, indeed, a type of PROM that can be erased electrically (as opposed to UV-EPROM).

However, the terms are commonly used with distinct meanings, as you suggest:

"FLASH" block-erasable - intended for code storage;

"EEPROM" byte-eraseable - intended for data storage.

Because "Flash" is commonly taken to mean "program (code) storage", this generally also implies that it has a lower erase endurance - ie, it is not designed for frequent re-writing.


Note that these are not hard-and-fast distinctions; they depend more on the context of the application than specific definitions!