Do you attend a school in which GPA is based on course grades rather than predicted IB scores? Will you earn a secondary school diploma in addition to the IB diploma? If so, your predicted scores will be reviewed, but your course grades will be the main basis for admission.
I was admitted RD to Cornell this year with a predicted score of 28, but a GPA in the top 5% of my class. I only earned 21 points and therefore did not receive the diploma, but still graduated with a standard diploma from my high school. Cornell seemingly did not care much about my predicted or final scores as they are obviously very low, but I was accepted and my admission was not rescinded.
If your GPA is linked to your predicted scores and the IB diploma will be your only proof of graduation, then these scores will be much more important. Although 38 may be below average for a highly selective school like Cornell, it is still a very good score and I am sure it is within the range of scores that they regularly admit. Your average across all subjects is 6, and they offer credit for that score on several tests, so they must not look down on those who receive or are predicted to receive them.
I was not admitted to the School of Hotel Administration, but I have heard that they absolutely love applicants who already have experience in the hospitality industry, so you have that going for you. Applying ED as legacy will boost your chances as well. Although everyone’s odds are inherently low, you should have a decent shot at admission.
Good luck!