In order to make your comparison valid, you would need to include hedging costs since her contract puts a floor on losses and what you are using doesn't... and those hedging costs would likely be very significant.
Also, from what you wrote this person would never have invested in SPY or QQQ without some or of floor... so since the floor was an important aspect of her investment decision then you need to proide for it in your analysis.
I would agree with you if there really was a floor, but from what I saw of how the gains and losses were calculated, losses count at full value and gains are capped.
At any rate, I cannot recommend that she stay in this “investment” knowing that if she had invested in the exact same ETF’s outside of this vehicle, she’d be over $130K better off in just 4 years. Her file didn’t have the 2018 statement in it but given recent volatility I’ll bet it’s more of the same so the gap will be even bigger.
If this were your friend or family member, would you recommend staying with this annuity?