Apex20 — Privacy & Data Policy

Operated by Apex20 Performance Groups Ltd. (the legal entity that operates the Apex20 service) Service: Apex20 — a dealer-owned peer benchmarking web portal at apex20groups.com (the former dealer20.ca address now redirects here permanently) Effective date: July 17, 2026 Last updated: July 17, 2026

1. The short version (plain English)

Apex20 is a private web portal where a group of car dealerships compare how their stores are performing against each other. To do that, members upload their monthly financial statements and a supplement spreadsheet. We combine that information into an anonymized Group Benchmark Report so each store can see where it ranks and where it might have room to improve.

This document explains, in plain language:

• what information we collect,
• how we use it,
• who can see it,
• the outside services we rely on,
• how we protect and retain it, and
• the legal terms that apply when you use Apex20 — including important limits on our responsibility and an explanation of what the portal is (and is not) meant to do.

By creating an account, signing in, or uploading information to Apex20, you agree to this Privacy & Data Policy. If you do not agree, please do not use the portal.

A few things to know up front:

• The numbers and benchmarks in Apex20 are for information and benchmarking only. They are not financial, accounting, tax, or legal advice. (See Section 11.)
• The benchmarks are built from data that members upload. We do not independently audit that data, and we cannot guarantee it is accurate or complete. (See Section 12.)
• You are responsible for the accuracy of what you upload and for having the authority to share it. (See Sections 8 and 12.)

2. Who this policy covers

This policy applies to everyone who uses Apex20, including:

• Members — dealership staff with an Apex20 account.
• Group reviewers — designated leaders at a member dealership (for example, a Dealer Principal or General Manager) who are given group-level visibility.
• Operator administrators — Apex20 Performance Groups Ltd. super-admins who run and support the portal.

"We," "us," and "our" mean Apex20 Performance Groups Ltd., the operator of Apex20. "You" and "your" mean the member dealership and its authorized users.

3. What we collect

We collect the following categories of information:

a. Account and profile information - Your name and email address. - If you sign in with Google, the basic profile and email information that Google provides through Google Sign-In (we use this to create and authenticate your account).

b. Financial and operating data you upload - Your monthly financial statements. - The manual supplement spreadsheet you complete each period. - Any other files or figures you choose to submit through the portal.

c. AI assistant content - Your chat history with "Della," the portal's built-in AI assistant, including the questions you ask and the responses provided.

d. Survey and meeting-preparation responses - Your answers to pre-meeting surveys and any other questionnaires we run inside the portal.

e. Usage and audit logs - Technical and activity records such as sign-in events, pages and reports viewed, uploads, and other actions taken in the portal. We use these for security, troubleshooting, and to keep an audit trail.

We do not seek to collect special categories of personal information (such as health information). Please do not upload personal information about individuals beyond what is reasonably necessary to operate your dealership account.

4. How we use your information

We use the information described above to:

• Run the peer benchmarking group — compile uploaded data into the anonymized Group Benchmark Report, calculate each store's ranking, and produce profit-opportunity estimates.
• Provide AI-assisted coaching — power the "Della" assistant so you can ask questions about your store's results.
• Operate your account — authenticate sign-ins, manage roles and permissions, and deliver the features you use.
• Provide support — respond to your questions and help resolve issues.
• Maintain security and integrity — detect, investigate, and prevent unauthorized access, misuse, or technical problems, and keep audit logs.
• Improve the service — understand how the portal is used and make it work better.
• Communicate with you — send service-related messages such as notices about uploads, reports, meetings, or changes to the portal.

We do not sell your information.

5. Who can see your information (role-based visibility)

Apex20 is built around role-based access, which means what a person can see depends on their role:

• Each store's own data is stored separately, per store.
• A member can see the detail for their own store, plus the anonymized Group Benchmark Report and group-level comparisons.
• Group reviewers (designated Dealer Principal / GM roles) can see group-level data as part of leading and reviewing the benchmarking group.
• Operator administrators (Apex20 Performance Groups Ltd. super-admins) can access group-level and store-level data as needed to operate, support, secure, and maintain the portal.

The Group Benchmark Report is designed to present peer comparisons in an anonymized form. However, please understand that in a small group, or where a store has distinctive numbers, it may sometimes be possible for a knowledgeable reader to infer which figures belong to which store. By participating, you accept this inherent characteristic of peer benchmarking.

6. Outside services we rely on (subprocessors)

To run Apex20, we use a small number of trusted third-party service providers. Each receives only the information needed to perform its function:

These providers operate under their own terms and privacy practices. We are not responsible for the independent acts or omissions of these providers, but we select providers we consider reasonable for the service. We may change or add service providers from time to time; if we do, we will keep this list reasonably current.

Where any provider stores or processes data outside Canada (for example, certain sign-in or AI features), that data may be subject to the laws of the jurisdiction where it is processed.

7. How we protect your information (security)

We take reasonable steps designed to protect the information in Apex20, including:

• Access controls and roles — visibility is limited based on each user's role (see Section 5).
• Encryption in transit — connections to the portal use HTTPS.
• Role-based visibility — store-level data is segregated and shown only to those permitted to see it.
• Backups — the hosting environment performs regular backups to support recovery.

No system is perfectly secure. While we work to protect your information, we cannot and do not guarantee that the portal or its data will never be accessed, altered, or disclosed in breach of our safeguards. You acknowledge that you provide your information at your own risk and are responsible for keeping your sign-in credentials confidential.

8. Member responsibilities

When you use Apex20, you agree that you will:

• Have the authority to upload and share the data you submit, including any required approvals from your dealership and any affected third parties.
• Submit accurate, complete information to the best of your ability — the quality of the benchmarks depends on it.
• Keep your credentials secure and not share your account, and promptly tell us if you suspect unauthorized access.
• Use the portal lawfully and only for legitimate benchmarking and management purposes for your dealership.
• Respect the confidentiality of the group — the Group Benchmark Report and other members' information are shared with you in confidence and must not be redistributed outside your dealership or used to harm another member.
• Not misuse the service — for example, by attempting to identify, reverse-engineer, scrape, or de-anonymize other stores' data, or by interfering with the portal's operation.

9. Data retention, deletion, and your rights

Retention. We keep your information for as long as your dealership is an active member and for a reasonable period afterward to meet operational, backup, legal, and recordkeeping needs. Backup copies may persist for a period after deletion from the live system before they are overwritten in the normal backup cycle.

Deletion / purge. You may ask us to delete or purge your account information and uploaded data. We will take reasonable steps to do so, subject to: - information we must keep to comply with law or to resolve disputes; - information already incorporated into anonymized, aggregated benchmarks (which cannot practically be unwound from past group reports); and - copies that remain in routine backups until they age out.

Your choices and rights. Subject to applicable Canadian privacy law, you may: - access the personal information we hold about you, - request correction of inaccurate information, - withdraw consent or close your account (which may mean you can no longer use the portal), and - ask questions about how your information is handled.

To make a request, contact us using the details in Section 18. We may need to verify your identity and your authority to act for the dealership before responding.

Consent. By using Apex20 and submitting information, you consent to the collection, use, and disclosure of that information as described in this policy. You may withdraw consent at any time on a going-forward basis, but doing so may prevent you from using some or all of the portal.

10. Service provided "AS IS" — disclaimer of warranties

The Apex20 portal, the Group Benchmark Report, the "Della" assistant, and all related content, reports, estimates, and features are provided on an "AS IS" and "AS AVAILABLE" basis, with all faults and without warranty of any kind.

To the fullest extent permitted by law, we disclaim all warranties, conditions, and representations of any kind, whether express, implied, statutory, or otherwise, including (without limitation) any implied warranties or conditions of merchantability, fitness for a particular purpose, accuracy, title, and non-infringement, and any warranties arising from course of dealing or usage of trade.

We do not warrant that the portal will be uninterrupted, timely, secure, error-free, or free of harmful components, or that any results, benchmarks, rankings, or estimates will be accurate, reliable, or suitable for your purposes.

11. For informational and benchmarking purposes only — not professional advice

Apex20 is provided for general information and peer benchmarking purposes only.

The portal, including its reports, rankings, profit-opportunity estimates, and anything generated by the "Della" assistant, does not constitute and must not be relied upon as financial, accounting, tax, legal, investment, or other professional advice. It is not a substitute for the judgment of qualified professionals who know your specific situation.

You are solely responsible for any decision you make or action you take based on the portal, and for obtaining your own professional advice before acting. We are not acting as your advisor, accountant, auditor, or fiduciary.

The "Della" AI assistant generates responses automatically and may produce information that is incomplete, outdated, or incorrect. Always verify AI-generated output before relying on it.

12. Accuracy and data disclaimer

The benchmarks, rankings, comparisons, and estimates in Apex20 are derived from data that members upload. We do not independently verify, audit, or validate that data.

Accordingly:

• We do not warrant the accuracy, completeness, currency, or reliability of any benchmark, ranking, estimate, or other output.
• You are responsible for the accuracy and completeness of the data you upload, and for ensuring you have the authority to share it.
• Outputs depend on the data and assumptions used and may differ from your actual results or from figures prepared under formal accounting standards.

You use the benchmarks and estimates at your own risk.

13. No guarantee of availability or uptime

We do not guarantee that Apex20 will be available at any particular time or that access will be continuous or uninterrupted. The portal may be unavailable due to maintenance, updates, hosting or third-party service issues, or events beyond our reasonable control. We may modify, suspend, or discontinue any part of the portal at any time, with or without notice, without liability to you.

14. Limitation of liability

To the fullest extent permitted by applicable law:

a. No indirect or consequential damages. We (including Apex20 Performance Groups Ltd. and its owners, employees, contractors, and service providers) will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, data, or anticipated savings, arising out of or related to the portal or this policy, even if we have been advised of the possibility of such damages and even if a remedy fails of its essential purpose.

b. Aggregate cap. Our total aggregate liability for all claims arising out of or related to Apex20 and this policy, whether in contract, tort (including negligence), warranty, statute, or otherwise, will not exceed the total amount of fees actually paid by your dealership to us for the Apex20 service in the three (3) months immediately before the event giving rise to the claim.

c. Basis of the bargain. You acknowledge that the fees for Apex20 reflect the allocation of risk in this policy, and that these limitations are a fundamental basis of the agreement between us.

d. Statutory rights. Some jurisdictions do not allow certain exclusions or limitations of liability. Nothing in this policy excludes or limits any liability that cannot be excluded or limited under applicable law. Where a disclaimer or limitation is not fully enforceable, it applies to the maximum extent permitted, and our liability is limited to the smallest amount permitted by law.

15. Indemnification by the member

To the fullest extent permitted by law, you (the member dealership) agree to defend, indemnify, and hold harmless Apex20 Performance Groups Ltd. and its owners, employees, contractors, and service providers from and against any and all claims, demands, actions, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or related to:

• the data and content you upload or submit to the portal;
• your breach of this policy or of any law;
• your lack of authority to share data you submitted;
• your use of the portal, the Group Benchmark Report, or its outputs, including any decision you make based on them; or
• your violation of the rights of any third party.

16. Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, notify members through the portal or by email. Changes take effect when posted, unless we say otherwise. Your continued use of Apex20 after a change means you accept the updated policy.

17. Governing law

This policy and any dispute relating to it or to Apex20 are governed by the laws of the Province of Saskatchewan and the federal laws of Canada applicable there, without regard to conflict-of-laws rules. You agree to the exclusive jurisdiction of the courts located in Saskatchewan, Canada, for any dispute, except where applicable law requires otherwise.

18. Contact us

If you have questions, requests, or concerns about this policy or your information, contact:

Apex20 Performance Groups Ltd. — Apex20 Mailing address: PO Box 1015, Indian Head, SK S0G 2K0 Email: privacy@apex20groups.com Portal: apex20groups.com

By using Apex20, you acknowledge that you have read and understood this Privacy & Data Policy and agree to it.