Free Traffic Legal Advice

Can you tell me if this is an appropriate appeal please? Thanks

"Dear UK Parking Control Ltd,
​I am the Registered Keeper of the above vehicle and I am appealing this parking charge. I decline to identify the driver.
​1. Failure to allow a Consideration Period (BPA Code of Practice)
The photographic evidence provided on your portal spans a total time of just 20 seconds, with the first image time-stamped at 14:05:48 and the final image at 14:06:08.
​Under the British Parking Association (BPA) Single Code of Practice, operators must provide a minimum consideration period of five minutes to allow drivers sufficient time to locate the signage, read the terms and conditions, and decide whether to accept them or leave the site. An observation window of merely 20 seconds conclusively proves that the driver was not granted the mandatory five-minute consideration period. Consequently, no parking contract was ever formed between the driver and UKPC. 
​2. Failure to comply with the Protection of Freedoms Act (PoFA) 2012
Your Notice to Keeper also fails to comply with the strict requirements of Schedule 4 of the Protection of Freedoms Act (PoFA) 2012. Specifically, you have failed to comply with paragraph 9(2)(a), as the notice does not specify the "period of parking" to which the notice relates. Providing a single timestamp of "14:06:14" merely indicates a single moment in time, which does not constitute a period of parking.
​Because your Notice to Keeper is not fully compliant with statutory requirements, you cannot lawfully transfer liability from the unknown driver to me, the Registered Keeper.
​As you have failed to establish keeper liability under PoFA 2012, and your own evidence proves no contract was formed with the driver under the BPA Code of Practice, you have no lawful basis to pursue this charge.
​I require you to cancel this charge immediately. If you choose to reject this appeal, you must issue a POPLA code so that this matter can be referred to independent arbitration, where these errors will mandate cancellation.
​Yours faithfully,
​The Registered Keeper"

Hi everyone, I am seeking some advice on a Notice to Keeper I have received.
The Situation:
On 22/05/2026, the driver parked a vehicle at the Bridge Retail Park on Hele Road, Torquay (TQ2 7PY). The driver believed they were parked appropriately and left the vehicle to visit the retail park.
On 30/05/2026, I received a Notice to Keeper through the post from UK Parking Control Ltd (UKPC). The alleged breach is that the vehicle was "Not parked correctly within the markings of the bay or space". They are demanding a £100 parking charge, discounted to £60 if paid within 14 days.
I am the Registered Keeper of the vehicle, and I am dealing with this as the Keeper. I have not yet responded to UKPC or lodged an appeal.
The Notices:
I have attached images of all pages of the notice received, with my personal details, PCN reference, and vehicle registration mark redacted as per the forum rules:
Front of the Notice to Keeper: https://ibb.co/DD466qmt
Back of the Notice to Keeper: https://ibb.co/bgLPxyZM
Signage:
I do not currently have close-up photos of the signage at the car park, but I intend to acquire these as soon as possible and will host them on an image-sharing site to link here.
Any initial advice on how to structure the appeal to UKPC (and potentially POPLA) based on this alleged "out of bay" breach would be greatly appreciated. Thank you in advance for your time and help!