The problem is that 37 signals qualified the statement. They're claiming there are 3 million "people who use our web-based apps". That pretty explicitly means active and current users of their products. If they said they had 3 million registered users that'd be an entirely different thing, and, ya'know: true.
The question is not about what the _lone word_ "user" means. That's obviously not specific enough to have a single definition.
The question is what does "3 million people who use our web-based apps" mean.
A simple truth test: Are there "3 million people who use [their] web-based apps"? Absolutely not. Not under even the most remotely reasonable definition.
Of course you are assuming that there are not 3 million active and current users of their products. If you consider that many people have multiple user accounts on 37signals products (and that they count free but active users too) it is not unreasonable.